J/RC: Retail and centres

Support the policy to protect small high streets

This needs to be carefully assessed in light of the Covid changes that may now become permanent.

Abrdn supports the ambition to update the existing retail policies to reflect the new Use Class E. Abrdn also supports the city centre approach to retail, recognising that this is the most sustainable location for such uses.

Abrdn notes the ambition to use proposed policy J/RC to support the retention of retail and leisure uses with the revitalisation of high streets. However, it is critical that the policy allows sufficient flexibility for complementary uses to come forward in retail areas. The well documented decline in demand for retail space means that for high streets and town centres to thrive, there needs to be an element of re-purposing and an increased leisure and residential offering in these areas.

Abrdn submitted the attached topic paper to the Council in July 2021 which provided evidence on the key retail trends, including the shift to online shopping and the resultant lower footfall in retail areas. These trends have been accelerated by the COVID-19 pandemic and whilst footfall is expected to increase again post-pandemic, it is unlikely to recover to pre-pandemic levels as the online shopping trend has been accelerated. There needs to be a recognition of this in planning policy, by allowing for more flexible uses.

As recently discussed with the Council’s policy team, Abrdn is actively managing Lion Yard to encourage new occupiers. Abrdn’s has adopted an approach to proactive asset management for ensuring the continuing role of Lion Yard in maintaining the vitality and viability of the city centre. Abrdn’s approach to its assets is based around ensuring that it can adapt to changing circumstances that affect the performance of its assets. It is essential that the planning system is sufficiently flexible to allow that adaptability to take place.

To ensure this strategy is successful in retaining the vibrancy of Lion Yard, it is vital planning policy
supports flexible uses. To enable asset managers to effectively respond to these changes, proposed policy J/RC should support all uses within Use Class E in retail areas. This is vital to ensure that an overly restrictive retail policy does not stifle economic growth and threaten the role of places like Lion Yard.

City centres are evolving from just offering retail to becoming experiential destinations, with a plethora of different uses such as gyms, health centres, offices and food & beverage quarters and consolidating complementary uses into a successful and sustainable places. In recent years, the changing dynamics and economics of the high street has placed significant pressure on the ability of investors to curate the places that they want to provide. This has been recognised by the Government in changes that it has introduced, such as the new Class E.

Abrdn is therefore supportive of its ability to change uses within Class E and to introduce non-Class E uses within the city centre such as cinemas and leisure facilities which can complement retail uses and ensure retail areas in Cambridge continue to flourish. The city centre is a destination and Lion Yard could help draw in more visitors if it had a greater variety of uses. Residents and visitors want a consolidated experience which includes leisure, offices, the night-time economy and food and beverage options, rather than just retail and the need to keep people coming to the city centre, to stay longer and keep the centre alive, should be reflected in the emerging Local Plan policy.

Abrdn recognises that different retail areas across Greater Cambridge operate in different contexts. Abrdn therefore supports the proposed approach of developing a specific approach to retail policy for Cambridge city centre, including its shopping centres. Abrdn is pleased to note the following in the proposed approach: “Through development of future guidance, the Council would seek to work through the issues with landowners with the objective of achieving vitality and vibrancy for these important parts of the City.” As a major landowner of retail assets within Cambridge city centre, Abrdn looks forward to working collaboratively with the Council on how to continue to achieve vitality and vibrancy for its assets and the wider city centre in the future. Abrdn has previously provided the Council with a topic paper to inform the development of the retail policies and is encouraged that the Council is taking a more flexible approach to retail in Greater Cambridge.

Abrdn disagrees with bullet point three which states that where planning permission is required, the Council will continue to resist the loss of retail or other town centre uses in existing centres and primary shopping areas where it would undermine their vitality or ability to serve local communities.

Abrdn would also strongly object to any Article 4 Directions that sought to restrict alternative uses as these can often improve the vitality of city centres by diversifying the mixture of uses and bringing more people into city centres at different times of the day.

Abrdn welcomes the Councils’ offer to engage with investors about their future ambitions for the city centre, and would be pleased to continue the engagement process as the plan’s preparation continues.

USS supports the proposed approach to support retail within new mixed use developments which are located outside of district centres. This will be important to ensure new residents have local everyday facilities that can be accessed sustainably, for example by walking or cycling.

Huntingdonshire District Council supports the proposed policy direction.

The department welcomes the plan’s reference to diversification of uses on high streets potentially improving their appeal to local communities. While education is not necessarily a town centre use, it can lead to significantly increased footfall in struggling retail areas. CMS will have up to 200 students aged 16-19, with a high degree of independence in shopping, eating out and supporting the night-time economy. We recommend that the final policy makes an allowance for education as a use which can support the long-term vibrancy and appeal of town and city centres. This would be consistent with the amended Use Classes Order which allows many town centre uses to be changed to a state-funded school without express planning consent. We recommend that Greater Cambridge policies accept the principles of that legislative framework, rather than attempting to block permitted development rights through Article 4 Directions.

Policy should have a strong focus on supporting village shops and services.

No mention of cycle safety - villages often have rubbish cycle storage, no space for cycle trailers, Cambridge has appalling bike crime. None of these proposals work if you don't improve cycle storage and cycle safety. It is part of the mix of this issue.

USS supports the ambition to update the existing retail policies to reflect the new Use Class E. USS also supports the city centre approach to retail, recognising that this is the most sustainable location for such uses.

USS notes the ambition to use proposed policy J/RC to support the retention of retail and leisure
uses with the revitalisation of high streets. However, it is critical that the policy allows sufficient flexibility for complementary uses to come forward in retail areas. The well documented decline in demand for retail space means that for high streets and town centres to thrive, there needs to be an element of re-purposing and an increased leisure and residential offering in these areas. For example, footfall in Cambridge is considerably down on 2019 levels and the COVID-19 pandemic has accelerated the long-term trend of a shift to online shopping. Whilst footfall is likely to increase post-pandemic, it is unexpected to rebound to pre-pandemic levels due to the advances in online shopping and associated shopping habits.

To enable asset managers to effectively respond to these changes, proposed policy J/RC should support all uses within Use Class E in retail areas. This is vital to ensure that an overly restrictive retail policy does not stifle economic growth and risk the creation of unoccupied and/or derelict sites. USS has previously submitted the attached topic paper (Greater Cambridge Local Plan and Retail Evidence Base Response on behalf of Universities Superannuation Scheme, dated July 2021) to the Council which sets out background to the current retail trends. USS requests that this evidence is considered in the development of a more flexible retail policy.

USS is also supportive of non-Class E uses within the city centre such as cinemas and leisure facilities which can complement retail uses and ensure retail areas in Cambridge continue to flourish. Consumer demand is pivoting towards experience-led shopping destinations and accessible convenience-oriented retail places and planning policy needs to reflect this.

USS recognises that different retail areas across Greater Cambridge operate in different contexts. USS therefore supports the proposed approach of developing a specific approach to retail policy for Cambridge city centre, including its shopping centres. USS is pleased to note the following in the proposed approach: “Through development of future guidance, the Council would seek to work through the issues with landowners with the objective of achieving vitality and vibrancy for these important parts of the City.” As a major landowner of retail assets within Cambridge city centre, USS looks forward to working collaboratively with the Council on how to continue to achieve vitality and vibrancy for its assets and the wider city centre in the future. USS has previously provided the Council with a topic paper to inform the development of the retail policies and are encouraged that the Council is taking a more flexible approach to retail in Greater Cambridge.

USS disagrees with bullet point three which states that where planning permission is required, the
Council will continue to resist the loss of retail or other town centre uses in existing centres and primary shopping areas where it would undermine their vitality or ability to serve local communities. If planning permission is required, it is unlikely that the new use would undermine vitality, otherwise the use would not be coming forward. USS therefore considers it unnecessary to include this in the proposed policy. USS would also strongly object to any Article 4 Directions that sought to restrict alternative uses as these can often improve the vitality of city centres by diversifying the mixture of uses and bringing more people into city centres at different times of the day.

USS supports the ambition to update the existing retail policies to reflect the new Use Class E. USS also supports the city centre approach to retail, recognising that this is the most sustainable location for such uses.

USS notes the ambition to use proposed policy J/RC to support the retention of retail and leisure
uses with the revitalisation of high streets. However, it is critical that the policy allows sufficient flexibility for complementary uses to come forward in retail areas. The well documented decline in demand for retail space means that for high streets and town centres to thrive, there needs to be an element of re-purposing and an increased leisure and residential offering in these areas. For example, footfall in Cambridge is considerably down on 2019 levels and the COVID-19 pandemic has accelerated the long-term trend of a shift to online shopping. Whilst footfall is likely to increase post-pandemic, it is unexpected to rebound to pre-pandemic levels due to the advances in online shopping and associated shopping habits.

To enable asset managers to effectively respond to these changes, proposed policy J/RC should support all uses within Use Class E in retail areas. This is vital to ensure that an overly restrictive retail policy does not stifle economic growth and risk the creation of unoccupied and/or derelict sites. USS has previously submitted the attached topic paper (Greater Cambridge Local Plan and Retail Evidence Base Response on behalf of Universities Superannuation Scheme, dated July 2021) to the Council which sets out background to the current retail trends. USS requests that this evidence is considered in the development of a more flexible retail policy.
USS is also supportive of non-Class E uses within the city centre such as cinemas and leisure facilities which can complement retail uses and ensure retail areas in Cambridge continue to flourish. Consumer demand is pivoting towards experience-led shopping destinations and accessible convenience-oriented retail places and planning policy needs to reflect this.

USS recognises that different retail areas across Greater Cambridge operate in different contexts. USS therefore supports the proposed approach of developing a specific approach to retail policy for Cambridge city centre, including its shopping centres. USS is pleased to note the following in the proposed approach: “Through development of future guidance, the Council would seek to work through the issues with landowners with the objective of achieving vitality and vibrancy for these important parts of the City.” As a major landowner of retail assets within Cambridge city centre, USS looks forward to working collaboratively with the Council on how to continue to achieve vitality and vibrancy for its assets and the wider city centre in the future. USS has previously provided the Council with a topic paper to inform the development of the retail policies and are encouraged that the Council is taking a more flexible approach to retail in Greater Cambridge.

USS disagrees with bullet point three which states that where planning permission is required, the
Council will continue to resist the loss of retail or other town centre uses in existing centres and primary shopping areas where it would undermine their vitality or ability to serve local communities. If planning permission is required, it is unlikely that the new use would undermine vitality, otherwise the use would not be coming forward. USS therefore considers it unnecessary to include this in the proposed policy. USS would also strongly object to any Article 4 Directions that sought to restrict alternative uses as these can often improve the vitality of city centres by diversifying the mixture of uses and bringing more people into city centres at different times of the day.

Will the City Centre be able to support Leisure activities? Traditionally these are outside the city centre. If so, transport plan is essential to out of town leisure facilities.

The intent of this policy is to identify the approach to retail and leisure uses across Cambridge. In Marshall’s work to date, proposals for Cambridge East include the potential to develop a local centre, but also accommodate complementary (rather than competitive uses) which cannot fit within the City Centre but which would enhance the overall Cambridge experience and offer. Within the ‘First Proposals’ consultation document and supporting evidence base, there is strong support for the type and mix of uses that Marshall is proposing. Section 3 of Part 2 of the Strategy Topic Paper notes that Cambridge East can provide:
- “A mix of employment uses, including offices, workshops and other uses, providing a variety of opportunities to support not only Cambridge’s high technology clusters, but also industry and creative uses, including local jobs to provide for existing communities and help contribute to community integration.” (page 114, Strategy Topic Paper)
- “A new centre for retail, cultural and other uses that will serve the urban quarter and wider area whilst complementing and not competing with the historic City centre.” (page 115, Strategy Topic Paper)
- All necessary supporting community infrastructure including primary and secondary schools” (page 115, Strategy Topic Paper)

It also states that:
- “Land at Cambridge East has long been recognised as having significant potential to be a sustainable major new eastern quarter for Cambridge, that is well connected to the rest of the City, with a mix of homes and a range of jobs and services and supporting infrastructure” (page 118-119, Strategy Topic Paper)
- “At Cambridge East there will be an opportunity to provide a range of new employment space that meets the needs of our key sectors identified in the ELR, including office / R&D floorspace and space for businesses that would provide local job opportunities for residents previously employed at Marshalls, as part of a mixed- use development, to help contribute to community integration.” (page 86, Strategy Topic Paper)

Marshall is pleased that the GCSP recognise that there is opportunity at Cambridge East to provide a range of retail and leisure services and facilities to serve the Greater Cambridge population and looks forward to collaborating with the GCSP, local community and local stakeholders to flesh out the range, scale and mix of uses that Cambridge East can accommodate.

We support the policy aims to ensure the inclusion of new retail centres appropriate to the scale of development to meet the day to day needs of local communities. The proposals for the expansion of the Campus will include an element of retail which will reduce journeys, support daily life on the Campus and meet residents’ and employees’ needs.

The policy direction includes establishing a hierarchy of centres across Greater Cambridge. This must also include the centres in the new settlements and new communities. The policy needs to support the provision and safeguarding of new centres in the new settlements to enable the residents to be able to walk or cycle to services and not have to use their car and travel to other centres.

With the increase in permitted development rights, it is becoming increasingly difficult to control the retention of shops and services. Consideration should be given in the policy saying that shops and services which provide a vital service will be protected through a condition removing permitted development rights or serving an article 4 direction.

There are empty shops.

Public transport is too expensive which encourages people to travel in cars.

Local Authorities are increasing charges for cars to travel in to the city centre, meaning there is nothing to encourage people into the town and city centres. There is a risk that the commercial centre of Cambridge will suffer considerably under current plans.

The policy should acknowledge the flexibility and scope that Class E provides to aid the revitalisation of high streets. Local authorities should be open to all manner of uses and mix of complimentary uses.
A positive and creative approach to town centres would enable delivery of housing and jobs in highly sustainable locations. Different residential models and work spaces are increasingly in demand and shopping practices are changing.
Policy must be flexible to accommodate rapidly changing market conditions such that projects are viable and can be delivered in a timely manner ensuring town centres remain successful.

Jobs policies
74. It is clear that the draft Local Plan is focused on the continuation of ‘growth’ in the Cambridge area. CPRE
believes this is a mis-guided approach. The Greater Cambridge area is one which DHSS would consider to
have effectively full employment, with just the usual rotation of people out of work or seeking work.
Therefore, any growth in jobs will require inward migration to fill them. Inward migration creates pressure
on local housing availability and prices, and hence pressure for more house-building. It is an anti-climate
cycle.
75. As stated above CPRE would like to see the skills and resources of Cambridge-based organisations used to
encourage employment and redevelopment in other regions of the country where housing and water
capacity already exist and, in doing so, greenhouse gas emissions would be minimised.
76. CPRE are concerned by policies J/RE: Supporting the rural economy and J/AL: Protecting the best
agricultural land. We think both of these policies should be strengthened and properly enforced. The rural
economy can be diversified but at its core are farmers and their interests must be protected. For example,
the opening up of tracks and bridleways on the scale proposed by the Greater Cambridge Partnership will
cause increasing levels of damage to farms and farm equipment and increased security risk to farm
properties. It will make illegal activities such as hare-coursing easier and the police enforcement job
harder.
77. We think it is in the national interest to stop building on South Cambridgeshire farm land, most of which is
Grade 2 with some Grade 3a. http://publications.naturalengland.org.uk/publication/127056 This land is already needed to assist the minimisation of food imports and it will be even more needed when the Fens
flood and national food supply is reduced by an estimated 20 – 25%.
78. According to the NFU, the Fens produce one third of England’s fresh vegetables, 20% of England’s potatoes,
more than 20% of England’s flowers and bulbs, 20% of England’s sugar beet as well as a significant
percentage of the country’s cereal, oilseed rape and protein crops. Agriculture in the Fens employs 80,000
people and produces £3bn pa for the rural economy.
79. The government recognises that the UK currently imports 45% of its food; however, some sources estimate
this to be as much as 80%. The Environmental Audit Committee has already warned government that the
UK cannot continue to rely on food imports on this scale because climate change is going to damage foodgrowing areas further south.
80. Building on good Cambridgeshire farm land just does not make sense. There may be short-term economic
pressures to do so but it is not in the national interest.
81. CPRE supports Policy J/PB: Protecting existing business space and Policy J/RW: Enabling remote working.
We also recognise that local affordable workspace can reduce commuting and increase local employment
opportunities, Policy J/AW: Affordable workspace and creative industries. We are concerned to ensure
that existing buildings which could be used for employment are not demolished to make way for maximum levels of housing and maximum profit for developers as we are aware has occurred in some districts.
82. With respect to Policy J/RC: Retail and centres, CPRE are aware of increasing levels of internet shopping
and decreasing footfall in retail centres. This may lead to re-purposing for housing under “Permitted
Development”. CPRE is believes that all such development should be brought back under local authority building control and not be the appalling low-quality free-for-all that it is now.

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.

I have asked Caldecote Parish Councillors to comment upon the emerging Local Plan.
There are no significant objections not the proposed sites.
Comments included were:
• Installation of charging points
• Bicycle lane and green walkways
• Adequate community facilities
• Access to mental health care
• Limited rural village development
• Small commercial/retail premises in rural communities
• Communication infrastructure (Fibre)
• Water consumption and the use of grey water
• Green space and more diversity
• Farming community to consulted.

This is a summary of comments received.

We support an update of the polices on retail and leisure. COVID has accelerated changes that were already happening. In Cambridge, as in other places across the country, shops are closing, leaving empty space. We hope that the policies on “retail and centres” will take account of this. There are clear links to other policies, such as housing, jobs and great places (but not limited to these) so our centres are not full of empty, under-used, buildings.
We welcome the intention to ‘establish a hierarchy of centres across Greater Cambridge’. As regards Cambridge itself, ‘encouraging small-scale units’ may not be sufficient to attract the range of users mentioned. The 2009 ‘Clone Town’ report from the New Economics Foundation highlighted a number of reasons for Cambridge’s lack of diversity as a shopping centre. These included the very high rents charged by landlords (mostly the Colleges, with this situation tied into the university’s own funding challenges); the frequent traffic gridlocks and the fact the Park and Ride services funnel shoppers into a few central locations.